On June 11, 2021 a
Proof of Service
was filed
involving a dispute between
Grant, Michael J.,
Mchale, Mark D.,
and
Does 1-50, Inclusive,
Lawson, William Richard,
for QUIET TITLE - REAL PROPERTY
in the District Court of San Francisco County.
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1 Nicholas A. Rogers, California Bar No. 248900
Aaron A Hayes, California Bar No. 236122
2 O’TOOLE ROGERS, LLP
3650 Mt. Diablo Blvd, Suite 180
ELECTRONICALLY
3 Lafayette, CA 94549
Telephone: 925.284.4693 F I L E D
4 Fax: 925.433.6627 Superior Court of California,
County of San Francisco
nrogers@otoolerogers.com
5 ahayes@otoolerogers.com 02/22/2022
Clerk of the Court
BY: SANDRA SCHIRO
6 Attorneys for Defendant Deputy Clerk
WILLIAM RICHARD LAWSON
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 IN AND FOR THE COUNTY OF SAN FRANCISCO
10
11 MARK D. MCHALE, an individual; No. CGC-21-592767
MICHAEL J. GRANT, an individual
12 PROOF OF SERVICE OF DEFENDANT
Plaintiffs, WILLIAM RICHARD LAWSON’S
13 DEMURRER TO FIRST AMENDED
vs. COMPLAINT
14
WILLIAM RICHARD LAWSON, an Date: March 29, 2022
15 individual, and DOES 1-50, inclusive, Time: 9:30 a.m.
Dept.: 501
16 Defendants.
17 Complaint Filed: June 11, 2021
Trial Date: N/A
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PROOF OF SERVICE
1 PROOF OF SERVICE
2 Case Name: Richard Lauckhart, et al. v. The El Macero Homeowners Association
3 Case No: Yolo County Superior Court No. CV2020-1489
4 I am employed in the County of Contra Costa, State of California. My business address is
O’Toole Rogers, LLP, 3650 Mt. Diablo Blvd., Suite 180, Lafayette, CA 94549. I am over the age
5 of eighteen years, and not a party to the within action.
6 On the date prescribed below, I served the within:
7
DEFENDANT WILLIAM RICHARD LAWSON’S NOTICE OF DEMURRER AND DEMURRER
8 TO FIRST AMENDED COMPLAINT
9 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANT WILLIAM
RICHARD LAWSON’S DEMURRER TO FIRST AMENDED COMPLAINT
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DECLARATION OF NICHOLAS A. ROGERS IN SUPPORT OF DEFENDANT WILLIAM
11 RICHARD LAWSON’S DEMURRER TO FIRST AMENDED COMPLAINT
12 [PROPOSED] ORDER GRANTING DEFENDANT WILLIAM RICHARD LAWSON’S
DEMURRER TO FIRST AMENDED COMPLAINT
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on the party[ies] listed below, addressed as follows:
14
15 SEE ATTACHED SERVICE LIST
16 ☒ By First Class Mail/Ordinary Business Practices [C.C.P. §§ 1013, 1013a]. By causing a
true copy thereof to be enclosed in a sealed envelope or package, addressed to the party[ies]
17 as stated on the attached service list. I am readily familiar with the firm's business practice
18 for collection and processing of envelopes and packages for mailing with the United States
Postal Service. Under the firm's practice, mail is deposited in the ordinary course of business
19 with the United States Postal Service at Lafayette, California, that same day, with postage
thereon fully prepaid. I am aware that upon motion of the party served, service is presumed
20 invalid if postal cancellation date or postage meter date on the envelope or package is more
than one day after the date of deposit for mailing.
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22 ☒ By Electronic Service (VIA EMAIL). The above document was served electronically on
the parties appearing on the attached service list associated with this case. A copy of the
23 electronic mail transmission[s] will be maintained with the proof of service document.
24 I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct. Executed on February 22, 2022 at Lafayette, California.
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By:
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Terri L. Nocco
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PROOF OF SERVICE
1 SERVICE LIST
2 Case Name: Richard Lauckhart, et al. v. The El Macero Homeowners Association
3 Case No: Yolo County Superior Court No. CV2020-1489
4
Michael W. Thomas, Esq.
5 THOMAS & ASSOCIATES
2390 Professional Drive
6 Roseville, CA 95661
Tel: 916-789-1201 / Fax: 916-789-1202
7 mthomas@thomas-lawyers.com
Assistant@thomas-lawyers.com (Asst.)
8 Attorneys for Plaintiffs
RICHARD LAUCKHART;
9 SHARON AND RONALD
BAUMGARTNER
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mthomas@thomas-lawyers.com; Assistant@thomas-lawyers.com
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DEFENDANT WILLIAM RICHARD LAWSON’S NOTICE OF DEMURRER
AND DEMURRER TO FIRST AMENDED COMPLAINT
Document Filed Date
February 22, 2022
Case Filing Date
June 11, 2021
Category
QUIET TITLE - REAL PROPERTY
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1 Nicholas A. Rogers, California Bar No. 248900 Aaron A Hayes, California Bar No. 236122 2 O’TOOLE ROGERS, LLP 3650 Mt. Diablo Blvd, Suite 180 ELECTRONICALLY 3 Lafayette, CA 94549 Telephone: 925.284.4693 F I L E D 4 Fax: 925.433.6627 Superior Court of California, County of San Francisco nrogers@otoolerogers.com 5 ahayes@otoolerogers.com 02/22/2022 Clerk of the Court BY: SANDRA SCHIRO 6 Attorneys for Defendant Deputy Clerk WILLIAM RICHARD LAWSON 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 IN AND FOR THE COUNTY OF SAN FRANCISCO 10 11 MARK D. MCHALE, an individual; No. CGC-21-592767 MICHAEL J. GRANT, an individual 12 PROOF OF SERVICE OF DEFENDANT Plaintiffs, WILLIAM RICHARD LAWSON’S 13 DEMURRER TO FIRST AMENDED vs. COMPLAINT 14 WILLIAM RICHARD LAWSON, an Date: March 29, 2022 15 individual, and DOES 1-50, inclusive, Time: 9:30 a.m. Dept.: 501 16 Defendants. 17 Complaint Filed: June 11, 2021 Trial Date: N/A 18 / 19 20 21 22 23 24 25 26 27 28 1 PROOF OF SERVICE 1 PROOF OF SERVICE 2 Case Name: Richard Lauckhart, et al. v. The El Macero Homeowners Association 3 Case No: Yolo County Superior Court No. CV2020-1489 4 I am employed in the County of Contra Costa, State of California. My business address is O’Toole Rogers, LLP, 3650 Mt. Diablo Blvd., Suite 180, Lafayette, CA 94549. I am over the age 5 of eighteen years, and not a party to the within action. 6 On the date prescribed below, I served the within: 7 DEFENDANT WILLIAM RICHARD LAWSON’S NOTICE OF DEMURRER AND DEMURRER 8 TO FIRST AMENDED COMPLAINT 9 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF DEFENDANT WILLIAM RICHARD LAWSON’S DEMURRER TO FIRST AMENDED COMPLAINT 10 DECLARATION OF NICHOLAS A. ROGERS IN SUPPORT OF DEFENDANT WILLIAM 11 RICHARD LAWSON’S DEMURRER TO FIRST AMENDED COMPLAINT 12 [PROPOSED] ORDER GRANTING DEFENDANT WILLIAM RICHARD LAWSON’S DEMURRER TO FIRST AMENDED COMPLAINT 13 on the party[ies] listed below, addressed as follows: 14 15 SEE ATTACHED SERVICE LIST 16 ☒ By First Class Mail/Ordinary Business Practices [C.C.P. §§ 1013, 1013a]. By causing a true copy thereof to be enclosed in a sealed envelope or package, addressed to the party[ies] 17 as stated on the attached service list. I am readily familiar with the firm's business practice 18 for collection and processing of envelopes and packages for mailing with the United States Postal Service. Under the firm's practice, mail is deposited in the ordinary course of business 19 with the United States Postal Service at Lafayette, California, that same day, with postage thereon fully prepaid. I am aware that upon motion of the party served, service is presumed 20 invalid if postal cancellation date or postage meter date on the envelope or package is more than one day after the date of deposit for mailing. 21 22 ☒ By Electronic Service (VIA EMAIL). The above document was served electronically on the parties appearing on the attached service list associated with this case. A copy of the 23 electronic mail transmission[s] will be maintained with the proof of service document. 24 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on February 22, 2022 at Lafayette, California. 25 26 --{27~ 27 By: 28 Terri L. Nocco 2 PROOF OF SERVICE 1 SERVICE LIST 2 Case Name: Richard Lauckhart, et al. v. The El Macero Homeowners Association 3 Case No: Yolo County Superior Court No. CV2020-1489 4 Michael W. Thomas, Esq. 5 THOMAS & ASSOCIATES 2390 Professional Drive 6 Roseville, CA 95661 Tel: 916-789-1201 / Fax: 916-789-1202 7 mthomas@thomas-lawyers.com Assistant@thomas-lawyers.com (Asst.) 8 Attorneys for Plaintiffs RICHARD LAUCKHART; 9 SHARON AND RONALD BAUMGARTNER 10 11 mthomas@thomas-lawyers.com; Assistant@thomas-lawyers.com 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 DEFENDANT WILLIAM RICHARD LAWSON’S NOTICE OF DEMURRER AND DEMURRER TO FIRST AMENDED COMPLAINT